Modern Slavery Policy

1. Purpose

Global Coaching Institute (GCI) is committed to operating in an ethical and responsible manner and ensuring that modern slavery and human trafficking do not occur in any part of our business or supply chains. This policy outlines our approach to identifying, mitigating, and addressing risks associated with modern slavery.

2. Scope

This policy applies to all employees, contractors, suppliers, and business partners of Global Coaching Institute. It aligns with our obligations under the Modern Slavery Act 2018 (Cth) and reflects our commitment to ethical business practices.

3. Definition of Modern Slavery

Modern slavery refers to situations where coercion, threats, or deception are used to exploit individuals and deprive them of their freedom. This includes, but is not limited to:

• Human trafficking
• Forced labour
• Child labour
• Debt bondage
• Forced marriage
• Exploitation through coercion, threats, or deception

4. Commitment to Ethical Business Practices

Global Coaching Institute is committed to:

• Ensuring that our operations and supply chains are free from modern slavery and human rights abuses.
• Conducting due diligence on our suppliers and business partners to assess and address risks related to modern slavery.
• Implementing and maintaining systems that identify and mitigate the risk of modern slavery within our operations.
• Providing training to employees to increase awareness and understanding of modern slavery risks.
• Encouraging and enabling the reporting of concerns relating to modern slavery.

5. Identifying and Addressing Risks

GCI acknowledges that modern slavery risks may exist within global and local supply chains. To address these risks, we will:

• Conduct risk assessments to identify suppliers, contractors, or business areas where modern slavery may be a concern.
• Ensure procurement practices include modern slavery risk evaluations.
• Engage with suppliers and request compliance with our ethical sourcing standards.
• Require suppliers to demonstrate efforts in identifying and mitigating modern slavery risks within their operations.

6. Reporting and Whistleblower Protections

Global Coaching Institute encourages employees, contractors, suppliers, and stakeholders to report any concerns related to modern slavery. Reports can be made confidentially through our Whistleblower Policy or directly to senior management.

Any reports will be investigated promptly, and appropriate action will be taken to address any identified risks or violations.

7. Training and Awareness

To foster a culture of compliance and ethical responsibility, Global Coaching Institute will:

• Provide training to employees on modern slavery risks and how to identify them.
• Integrate modern slavery awareness into procurement and supplier engagement processes.
• Encourage knowledge-sharing and collaboration to improve ethical business practices.

8. Continuous Improvement

Global Coaching Institute is committed to the continuous review and improvement of this policy to ensure its effectiveness. This includes:

• Regularly reviewing risk assessment processes and updating policies as required.
• Engaging with stakeholders to strengthen our approach to modern slavery prevention.
• Reporting transparently on our modern slavery risk management efforts.

9. Compliance and Accountability

Failure to comply with this policy may result in disciplinary action, including termination of contracts or business relationships where necessary. All employees, contractors, and suppliers are expected to adhere to this policy and contribute to our commitment to ethical business practices.

10. Policy Review

This policy will be reviewed annually to ensure alignment with legislative requirements and best practices.

Approval & Endorsement:
Approved by: Rho Sandberg
Position: Director
Date: 4 February 2025